Love2Meet NZ Member Privacy Policy

Last updated on 05 September 2018

Overview

Maintaining the security of your data is a priority at Venntro Media Group Ltd.
and we are committed to respecting your privacy rights. We pledge to handle
your data fairly and legally at all times. Venntro Media Group Ltd. is dedicated
to being transparent about what data we collect about you and how we use it.

This Privacy Policy (together with our
Terms of Use and any other documents
referred to in it) outlines the manner in which we manage personal information
obtained through or displayed on the Website or otherwise provided by users
(“you”, “your”) of our dating and networking services (“Services”) via the
Website. It applies whenever you visit this website, including any mobile
website (together the “Website”), and provides you with information about:

what personal data we collect;

how we use your data;

how long we retain your data;

how we ensure your privacy is maintained; and

your legal rights relating to your personal data.

Please read this policy carefully to understand our views and practices
regarding your personal data and how we will treat it. By using the Website,
you are taken to have read and agreed to the collection, use, disclosure and
handling of your personal information in accordance with this Privacy Policy.

Sharing your information with our other websites in the same network

Please note that to improve the opportunity to find a dating partner, our
Services are operated through a number of other websites in addition to this
Website (which may include all those operated by Venntro Media Group or any
subsidiary of Venntro Media Group including, but not limited to, Woowise
Ltd).

This means that when you sign up to our Services, any content you post to the
Website will be searchable and available to users of the Services who access
it via different websites in the same network as the Website. It also means
that you may view and communicate with other members of the Services who have
registered with and accessed the Service through different websites in the
same network. You will have no control over which websites within a network
your data is shared with, but you will always be able to block unwanted
individuals from any website within the network from accessing your profile
and interacting with you.

These will
only
be websites in the same network as this Website. These networks group you
together with members of the Services according to certain classifications,
so that your information will only be accessible to appropriate potential
dating partners who have signed up through a Website providing compatible
Services to this one.

By registering with this Website you acknowledge and accept that the
personal information you provide in connection with the Service may be shared
with our other websites in the manner described above.

Data Controller

For the purposes of the General Data Protection Regulation (“GDPR”) and any other data protection laws applicable in the UK, we confirm that
the data controller of this website is Venntro Media Group Ltd., a company
registered under the laws of England, whose registered office is
59-60 Thames Street, Windsor, SL4 1TX, United Kingdom and who also trades as
Global Personals and White Label Dating (“Venntro Media Group”, “we”, “us” and “our”).

What personal information do we collect about you and from whom?

When you access, subscribe or sign up to use the Website, we may collect a
variety of personal information about you, including:

some of the information you choose to provide us may be considered
"special" or "sensitive" in certain jurisdictions, for example your racial
or ethnic origins, sexual orientation and religious beliefs. By choosing
to provide this information, you consent to our processing of that
information;

personal information provided to us if you contact us, such as your
contact details in our records of that correspondence;

personal information provided to us if you choose to complete any surveys
or questionnaires for us, enter a competition or promotion of ours or
participate in forums, discussion boards or other social media functions
on our Website;

personal information if you post or transmit information via the Website
to other users; and

records of which of our Services you are interested in and which Services
you purchase.

any personal information you provide to any of the other websites we operate
or the other services we provide (in which case we will have informed you
when we collected that data that it may be shared internally and combined
with data collected on this site);

any relevant personal information that you may have submitted to our third
party service providers in the course of them providing the Services on our
behalf, including for example, business partners, sub-contractors in
technical, payment and delivery services, fraud prevention agencies,
advertising networks, analytics providers, search information providers,
credit reference agencies.

Why do we collect your personal information and on what grounds?

We will only use your personal data if we have a permitted lawful basis to do
so. Generally we collect your personal data because is it necessary for:

performing our contract
for the Services with you;

the pursuit of our
legitimate interests
(as set out below); or

complying with our
legal obligations.

We may also rely on
your consent
to use your personal data for:

marketing purposes (see “Marketing Communications” below);

administering prize draws, competitions or promotions; and

in order to collect certain sensitive personal data about you necessary to
provide the Services (including your sexuality, racial or ethnic origin or
your religious beliefs).

You have the right to withdraw your consent to these activities at any time,
which will mean (unless another lawful basis applies to your data) that we
will cease to process the affected data after consent is withdrawn. However,
please note this may result in us being unable to provide you with certain
features of the Website and/or Services.

The primary purpose for which we collect information about you is to provide
you with Services you have requested in subscribing or signing up to use the
Website (i.e. to perform our contract with you). We also collect information
about you for the following purposes:

To perform our contract with you

To process your communications, your membership of and subscription to the
Website and to enable your use of the Website and the Services;

For selling and supplying and services to you;

To provide customer care services. For the avoidance of doubt, we will only
store limited Credit Card or Debit Card information for the purpose of
assisting with customer care enquiries;

To open and run your account;

For continuity of service, (e.g. to restore your profile if you are coming
back onto the Website after a long break). This will be in accordance with
our data retention practices (see “How long do you keep hold of my personal
information?” below);

To provide you with information, products or services that you request from
us; and

For handling customer contacts, queries, complaints or disputes.

For our legitimate interests

For promoting, marketing and advertising our services;

For statistical and demographic analysis, in order to understand our
customers’ behaviour, activities, preferences, and needs;

For improving existing services and developing new products and services;

To protect Venntro Media Group Ltd. and our customers, by taking appropriate
legal action against third parties who have committed criminal acts or are
in breach of legal obligations to Venntro Media Group Ltd.;

To effectively handle any legal claims or regulatory enforcement actions
taken against Venntro Media Group Ltd.;

To provide you with an up to date, efficient and reliable Service;

To investigate any complaints about or made by you, or if we have reason to
suspect that you are in breach of the Website terms of use or that you have
otherwise engaged in any unlawful activity;

To generally run the Website and for internal operations, in order to
provide you with an up to date, efficient and reliable Service; and

To monitor and record telephone calls for training purposes and to improve
the Service to you.

To comply with our legal obligations

To help prevent fraudulent activity, including on your account (for example,
if we collect your card details we will check these details with credit
agencies and reserve the right to refuse to make available the Website
and/or our Services if, for example, the card details provided are reported
to be fraudulent or credit agencies report the activities as being
fraudulent);

To monitor and record telephone calls for training purposes and to improve
the Service to you;

For preventing, investigating and detecting crime, fraud or anti-social
behaviour and prosecuting offenders, including working with law enforcement
agencies; and

To fulfil our duties to our customers, colleagues, shareholders and other
stakeholders.

Marketing communications

Where you have opted into marketing communications, you agree that we may use
your information to contact you by your chosen method of electronic mail (e.g.
by email and SMS) about tailored offers, events, competitions, items or
related activities that you may find useful, as well as other similar products
and services offered by us or any of our related entities from time to time.
We do not sell, trade or rent your personal information to other companies and
partners.

You may receive marketing communications from Venntro Media Group Ltd. or through
any of our trading names, for example White Label Dating, during the term of
your membership (whether full or basic) unless you unsubscribe from receiving
such marketing communications as set out below.

How to unsubscribe from receiving Marketing communications?

If you have consented to receive marketing communications, you may always
revoke that consent at any time by changing your settings on the Website or
exercising the "unsubscribe" option in any marketing communications you get
from us.

Who do we disclose your information to?

We may disclose your personal information to any member of our group, which
means our subsidiaries, our ultimate holding company and its subsidiaries, as
defined in section 1159 of the UK Companies Act 2006.

We may also disclose your personal information to third parties:

authorised by you to receive information held by us (including other members
using the Website, associated websites and our Services);

for the purpose of asking that third party to provide goods or services on
our behalf, including but not limited to carrying out data analysis,
cleansing, processing credit card information, mail outs, debt collection,
marketing, research and advertising;

that are our agents, business partners or joint venture entities or
partners;

that are associated websites (as noted above, our Services may be offered
through and accessible via a number of other websites in addition to this
Website (“Associated Websites”) and data that you post to the Website for access by members of the
Website may be searchable and available to users of the Website Services who
access it via Associated Websites);

that sponsor or promote any competition that we conduct or promote via our
Services or

if we are under a duty to disclose or share your personal data with such
parties in order to comply with any legal obligation, or in order to enforce
or apply our terms of use; or to protect the rights, property, or our
safety, our customers, or others. This includes exchanging information with
other companies and organisations for the purposes of fraud protection and
credit risk reduction, or to the Police and any relevant authority or
enforcement body (including your Internet Service Provider or network
administrator).

You agree that if we transfer ownership or management of the Website, our
Services, the business and/or the assets (in whole or in part) to a third
party in the event that we sell, trade or licence any part of the business or
assets, that we may also transfer your personal data or other personal data
you have provided to us as part of those assets, including all sensitive
personal data and any other information about you to such third party,
provided such third party agrees to observe this policy.

How do we restrict access to your personal information on the Service?

We respect and are committed to protecting your privacy and that of other
users, and wherever possible we require you to provide login information and
identify yourself to access the Website.

We also make an effort to ensure that members of the Service are not connected
with other members that may be inappropriate. To do this we may apply
classifications to Associated Websites that provide access to the Service,
including to the Website. These classifications may restrict the availability
of:

communications between yourself and other members of the Service;

the details of other members of the Service to yourself; and

your details to other members of the Service.

How long do you keep hold of my personal information?

We remove onsite activity periodically throughout your membership. If you
delete your profile or your free profile is inactive for 18 months, all
information is deleted from the account and from the Company’s records apart
from your gender, sexuality and payment records (excluding card information),
which are all retained by the Company in an anonymous way. Profile information
is deleted from our servers within 10 hours from either the profile being
deleted or inactive for 18 months, or if the profile is active, from yourself
deleting or amending your personal information.

Do you transfer my personal data abroad?

All of your data is stored on our servers in the UK. However, a number of our
suppliers (including providers of our content delivery, cloud platform,
payment systems and mailing services) are based outside of the European
Economic Area, which may require us to transfer your personal data to
jurisdictions which are not subject to equivalent standards of data protection
laws (including the US). Where such international transfers are necessary, we
will ensure that these are made subject to appropriate safeguards (including
by using EU Commission approved standard contractual clauses). All
organisations who we transfer data to in the US are certified under the
Privacy Shield framework. You can request further details about the safeguards
we use when transferring your data abroad by contacting us at the details
below, and view the list of Privacy Shield participants on
https://www.privacyshield.gov/list.

Security of Personal Information

Transmission of data and information via the Website is not a secure or
encrypted transmission method for sending your personal data, unless otherwise
indicated on the Website. Accordingly, your attention is drawn to the fact
that any information and personal data carried over the internet is not secure
and any transmission is at your own risk. Information and personal data may be
intercepted, lost, redirected, corrupted, changed and accessed by other
people.

We take reasonable steps to protect the personal information we hold from
misuse and loss, and from unauthorised access, modification or disclosure. For
example, we set strict security standards to prevent any unauthorised access
to your personal information once we have received it and wherever possible we
will use adequate security software and working procedures to ensure the
security of your personal information. To prevent unauthorised access,
maintain accuracy, and ensure proper use of personal information, we have
employed physical, electronic, and managerial processes to safeguard and
secure the information we collect online.

Cookies

Our Website uses cookies to distinguish you from other users of our Website.
Cookies are small pieces of removable data that are stored by the web-browser
on your computer, mobile phone or other device that identifies your computer,
mobile phone or other device when you visit the Website. We use cookies to
improve the Website and the Services available to you.

For more information about the cookies we use and the purposes for which we
use them, please see our
Cookie Policy.

Your rights in respect of your personal data

Under certain circumstances, you have rights under data protection laws in
relation to the personal data we hold about you. You can request to:

access information held about you.
Please note that we reserve the right to request for proof of your ID to
process the request, and to charge you a reasonable administrative fee for
any repetitive, manifestly unfounded or excessive requests. If we refuse
your request to exercise this right, we will give reasons for our refusal
and allow you to challenge our decision.

rectify any incorrect or incomplete data we hold about you.
It is both in our interest and yours that any personal information we hold
about you is accurate, complete and current. If the data we hold about you
is inaccurate in any way, please contact us to have your personal
information corrected.

Please note that in respect of all these rights we reserve the right to refuse
your request based on the exemptions set out in the applicable data protection
laws.

If you have any concerns about how we handle your data, please contact us. If
you are not satisfied after we’ve tried to resolve your issue, you’ll be
entitled to lodge a complaint with our data protection regulator, the
Information Commissioner’s Office (ICO). Please see the ICO website for
further details,
https://www.ico.org.uk.

Third party links on the Website

Our site may, from time to time, contain links to and from the websites of our
partner networks, advertisers and affiliates. If you follow a link to any of
these websites, please note that (unless these are our Associated Websites)
these websites have their own privacy policies and that we are not in control
of, and do not accept any responsibility or liability for these policies or
any third party website linked to the Website. Please check these policies
before you submit any personal information through these websites.

Changes to this policy

We may review and amend this Privacy Policy to take into account changes in
law, technology and our operations. We will post any changes to this Privacy
Policy on the Website and, where appropriate, notify you by email. Please
periodically review this Privacy Policy before using the Website as continued
use of the Website shall indicate your acceptance of any changes. All personal
information held by us will be governed by the most recent Privacy Policy
posted on the Website.

Contact Us

If you have any questions or comments about this Privacy Policy, including
requests to access or modify the use of your personal data, you can contact
our Data Protection Officer by emailing
dataprotection@venntro.com.

For other general queries, Venntro Media Group can be contacted via the
contact section on the Website or by writing to our registered address.

To maximise your chances of finding success, we've enhanced the members’ area of Love2Meet NZ to include members with all interests and characteristics. You can still use our search settings to find exactly who you're looking for.